Murphy
MONTGOMERY, Ala. (Legal Newsline) - The Alabama Supreme Court has granted a former director of the state Department of Public Safety a writ of mandamus directing a circuit court to vacate its judgment against him.
The Court issued the writ on Friday, forcing the Montgomery Circuit Court to withdraw its judgment denying J. Christopher Murphy's motion to dismiss.
On July 21, 2008, Christopher Battle, individually and as a class representative, sued the department and Mike Coppage, the then-director of the department, requesting declaratory and injunctive relief and alleging claims of unjust enrichment and unlawful taking and seeking monetary damages.
Battle purported to bring the action on behalf of himself and others who had allegedly been overcharged by the department for renewed drivers' licenses.
On Feb. 13, 2009, an amended complaint was filed by Battle and Greg Ogles, individually and as representatives of two separate classes, dismissing the department as a defendant and substituting Murphy for Coppage as director. The amended complaint alleged that Battle had renewed his driver's license with the department in February 2005, that he was charged $23.25 for doing so and that the charge was in violation of state code.
The amended complaint also alleged that Ogles had, in late June or early July 2004, been charged $18.00 by the department for obtaining a duplicate driver's license. That charge also was in violation of state code, the complaint said.
The complaint further alleged that Murphy, as the director of the department at the time, had the authority to establish the charges and that the charges he established were beyond those statutorily permissible as the result of either a mistaken interpretation of the law or a willful misapplication of the law.
The amended complaint requested declaratory relief, injunctive relief and money damages under claims of unjust enrichment, and unlawful taking for the alleged overages paid to the department.
On Aug. 22, 2008, Murphy filed a motion to dismiss the action, asserting lack of subject-matter jurisdiction based on the doctrine of sovereign immunity. He also asserted that the respondents had failed to state a claim upon which relief can be granted. On May 15, 2009, he filed a motion for a summary judgment.
On Feb. 5, 2010, the circuit court denied Murphy's motion to dismiss and the summary judgment motion. Twenty-one days later, he filed a petition for a writ of mandamus with the state's high court. About seven months later, he resigned as director.
Justice Tom Parker authored the Court's 16-page opinion.
In it, the justices agree that Murphy demonstrated "a clear legal right" to dismiss.
A complaint seeking money damages against a state employee in his or her official capacity is considered a complaint against the State, and such a complaint is barred by the state constitution, the Court explained.
Further, the Court has held that actions to recover money damages from the State that seek to compel the payment of money the State is not legally obligated to pay pursuant to a contract are generally barred, it said.
"It is undisputed that the respondents are seeking money damages from the State," the Court wrote. "Although the respondents' action alleging that Murphy had improperly overcharged them for renewal and duplicate drivers' licenses based upon either a misinterpretation of the law or a willful misapplication of the law is not necessarily barred by the doctrine of sovereign immunity, a judgment in the respondents' favor would affect the financial status of the State treasury, and, thus, the action for money damages cannot be maintained.
"Accordingly, to the extent that the respondents' action seeks money damages from the State, it is barred by the doctrine of sovereign immunity."
From Legal Newsline: Reach Jessica Karmasek by e-mail at jessica@legalnewsline.com.